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In addition we note that depending upon the particular facts the issue of the preferred shares may contravene the condition (number 3) that the only transactions of the corporation relate to its objective of holding property for the personal use or enjoyment of the shareholder.  ...

In addition we note that depending upon the particular facts the issue of the preferred shares may contravene the condition (number 3) that the only transactions of the corporation relate to its objective of holding property for the personal use or enjoyment of the shareholder. ...

While again a question of fact, it is our general view that where this is undertaken solely to protect the investments of the mortgage investment corporation, such action would not contravene the provisions of paragraph 130.1(6)(b) of the Act. ...

In addition we note that depending upon the particular facts the issue of the preferred shares may contravene the condition (number 3) that the only transactions of the corporation relate to its objective of holding property for the personal use or enjoyment of the shareholder. ...

Paquette at (613) 954-2522 or to the following address: Coverage Policy and Legislation Section Source Deductions Division Revenue Canada Taxation 875 Heron Road Ottawa, Ontario K1A 0L8 If the Plan is adjusted to correct the aforementioned problems it is our opinion that it will not contravene the provisions in Regulation 8801. ...

You ask whether this would contravene the registration conditions in paragraphs 146.4(4)(a) and (i) of the Income Tax Act (the “Act”). ...

10 May 2016 Internal T.I. 2016-0644761I7- RPP borrowing Unedited CRA Tags 8502(i) Principal Issues: Whether a registered pension plan contravenes the borrowing restriction in Regulation 8502(i). ...

This contravenes one of the underlying principles in the taxation of capital gains regime, which is to prevent the indefinite deferral of tax on capital gains. ...

This contravenes one of the underlying principles in the taxation of capital gains regime, which is to prevent the indefinite deferral of tax on capital gains. ...

" Since the method proposed in document #9235160 takes into account the fair market value of the manufactured or processed goods, we are of the opinion that this method would not result in a portion of the non-resident's profit that is attributable to the manufacturing of the goods being taxed in Canada, nor would it contravene paragraph 4(1)(b) ITA. ...